Michelle M. Kelley

Senior Vice President

Associate Counsel

One Beacon Street, 22nd Floor

Boston, MA 02108-3106

michelle.kelley@lpl.com

617 897 4033 office

617 556 4002 fax

Member FINRA/SIPC

February 3, 2011

VIA ELECTRONIC MAIL to e-ORI@dol.gov

The Office of Regulations and Interpretations

Employee Benefits Security Administration

Attn: Definition of Fiduciary Proposed Rule

Room N-5655

U.S. Department of Labor

200 Constitution Avenue, NW

Washington, DC 20210

Ladies and Gentleman:

This letter responds to the request by the Department of Labor (“Department”) for 

comments on the Department’s proposed regulations on the definition of the term “fiduciary.”1 

We appreciate the opportunity to comment on the Proposal and related questions raised by the 

Department. 

I. Introduction

LPL Financial LLC (“LPL”) is one of the nation’s leading diversified financial services 

companies and is registered with the Securities and Exchange Commission (“SEC”) as both an 

investment adviser and broker-dealer. LPL currently supports the largest independent registered 

representative base2(referred to herein as “financial advisors”) and the fifth largest overall 

registered representative base in the United States, providing financial professionals with the 

front, middle, and back-office support they need to serve the large and growing market for 

brokerage services and independent investment advice. As a dual registrant, LPL is subject to 

regulation by the SEC for its investment advisory services, and the Financial Industry Regulatory 

Authority (“FINRA”), the SEC and the states for its broker-dealer activities. 

LPL provides a range of services with respect to its customers, which include various 

types of retail customers, including individual retirement accounts (“IRAs”), and others, such as 

plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) 

(collectively, IRAs and plans subject to ERISA are referred to as “retirement customers”). In 

addition to discretionary investment advisory services to retirement customers and other 

 

1

 75 Fed. Reg. 65263 (Oct. 22, 2010) (the “Proposal”).

2

 Investment Advisor’s Top 25 Independent Broker/Dealers, Investment Advisor, June 2010.
Member FINRA/SIPC - 2 -

customers, LPL provides a range of non-discretionary services to its ERISA plan customers, 

including services to assist plan fiduciaries in identifying and/or monitoring investment options 

available to plan participants for selection under their plans and providing investor education to 

plan participants. In its capacity as a registered broker-dealer, LPL offers, and effects purchase 

and sale transactions in, investments for retirement customers both subject to ERISA and those 

that, like IRAs, are not. A substantial portion of LPL’s business involves the provision of 

brokerage and related services, including clearing services, to customers, particularly IRAs. 

Through its trust company affiliate, LPL also serves as custodian for most of its IRA brokerage 

customers. 

LPL regularly produces research on general market and economic conditions and other 

investment-related topics and also provides additional research to its financial advisors for their 

use in providing services to LPL customers, including retirement customers. LPL financial 

advisors may also conduct seminars for customers and prospective customers on investmentrelated subjects and develop financial plans. 

Overview of Comments 

In the context of the foregoing, LPL offers a number of comments on the Proposal and 

also respectfully requests that the Department consider certain actions, as discussed in Section II 

below. 

As a threshold matter, LPL understands and supports the Department’s efforts to protect 

plan participants from undisclosed conflicts of interest and self-dealing by plan fiduciaries. LPL 

also appreciates the Department’s efforts to facilitate more effective enforcement against plan 

fiduciaries engaging in improper conduct under ERISA. 

Unanticipated Consequences

However, as explained further below, we have serious concerns about the broader, likely 

unanticipated impact that the Proposal would have on our current business operations, on other 

broker-dealers and other non-fiduciary service providers to retirement customers, and on the 

retirement customers themselves. We believe that there are better alternatives to addressing the 

issues the Department has asserted as bases for the Proposal and that these warrant serious 

consideration by the Department. For example, to the extent that the rationale for the Proposal is 

to protect retirement customers from undisclosed conflicts of interest, that objective could be 

readily obtained through disclosure, without the dramatic changes that the Proposal would 

engender. Furthermore, although one of the Department’s stated objectives in the Proposal is to 

provide a “clearer” understanding of when persons are providing fiduciary investment advice, we 

believe that the Proposal will instead likely amplify the confusion in the consumer marketplace 

about the standards of care owed by financial service providers to retail customers. In addition, 

we question whether the Proposal is consistent with the framework of ERISA. There also appear 

to be inconsistencies between the Proposal and the Dodd-Frank Wall Street Reform and 

Consumer Protection Act (the “Dodd-Frank Act”), particularly in the Proposal’s application in the 

context of derivatives.

Other commenters have stated, and we agree, that the Proposal, if finalized, will likely 

reduce or eliminate the services alternatives available to retirement customers. There is a very 
Member FINRA/SIPC - 3 -

real possibility that the new compliance and operational burdens resulting from the Proposal 

would cause many service providers, particularly broker-dealers, to restructure their service 

offerings to retirement customers (or cease their current offerings entirely), with the result that 

retirement customers may have fewer or less desirable (or more costly) options than are currently 

available to them. The Proposal does not fully analyze these consequences as to ERISA plans and 

does not provide any analysis as to its potential impact on IRAs (nor does the Proposal fully 

evaluate the potential impact on the service providers themselves).

Distributions and Rollovers

A further aspect of the services-related impact on retirement customers relates to 

providing information or recommendations relating to distributions from a participant’s plan 

account or the rollover of such participant’s assets to an IRA. The Department has inquired 

whether the Proposal should be modified to encompass this type of “advice” as a basis for 

fiduciary status. We strongly believe that treating the provision of information or 

recommendations about plan distributions and/or IRA rollovers as a basis for fiduciary status 

would not serve the interests of plan participants, since doing so would limit a participant’s 

choices regarding the management of his or her assets. We also believe that characterizing these 

distribution-related services as fiduciary advice fails to recognize the different capacities in which 

a service provider may act with respect to an ERISA plan or plan participant. As with the 

concerns that the Department has raised regarding conflicts of interest with respect to other 

services, we respectfully suggest that the Department’s concerns in connection with distributions 

or rollover-related information could be largely addressed by expanded disclosure requirements. 

Disclosure and Coordination with Other Regulators

Importantly, addressing the Department’s concerns regarding conflicts of interest by 

expanding current disclosure requirements would not require the dramatic alteration of current 

business practices and account documentation of, and types of services offered by, the financial 

services industry. The Department has recently completed several significant rulemakings with 

respect to plan and participant disclosure, and the Proposal seems to overlook the effect of these 

rulemakings and the possibility of using those new rules as a means of addressing currently 

undisclosed conflicts. 

We believe that enhanced disclosure is a meaningful vehicle available to the Department. 

The Department should be aware that we, like many financial services providers, are well on our 

way to developing expanded disclosure for prospective and existing ERISA plan customers to 

address the new requirements of the Department’s recent rulemakings.3 These disclosures 

supplement the disclosure obligations to retirement and other customers to which we are already 

subject under current requirements of the SEC and FINRA. Further, these regulators have also 

recently refined and improved their disclosure requirements. For example, effective this year, 

 

3

 As discussed further below, the Proposal interacts with (and may increase the difficulty of complying with) 

requirements of the Department’s recent rulemakings on disclosure, such as the requirement in the rule on reasonable 

contracts or arrangements under Section 408(b)(2) that a service provider determine and state whether it will provide 

services as a fiduciary. 29 C.F.R. § 2550.408b–2(c)(1)(iv)(B). The regulations under Section 408(b)(2) are effective 

July 16, 2011.
Member FINRA/SIPC - 4 -

new SEC rules require us and other investment advisers to deliver, in connection with Form ADV 

Part II, a new plain English disclosure document that contains disclosures of services, fees and 

potential conflicts of interest.4 In addition, as a matter of best practice broadly accepted by most 

broker-dealers, our website includes a section that specifically addresses conflicts of interest and 

compensation arrangements we have with investment products sponsors and other persons. Thus, 

despite the stated rationale for the Proposal as necessary to address the problem of undisclosed 

conflicts, the Proposal presents an overly broad and, indeed, unnecessary means of achieving the 

Department’s expressed objective. 

Shift in the Definition of Fiduciary

We also believe that the Proposal presents an unwarranted, and perhaps impermissible, 

shift in the definition of “fiduciary” as set forth in ERISA and as interpreted in substantial case 

law from being determined by a person’s actions to being determined by the person’s status 

and/or the expectations of the recipient of the services. 

Further, we strongly believe that any change in the standards applicable to investment 

advisers and broker-dealers that provide services to retirement customers, particularly one as 

dramatic as contemplated in the Proposal, to be comprehensively and fairly accomplished, 

requires coordination with the SEC and other governmental agencies that are charged with 

studying harmonization of the applicable regulatory structure and/or provide oversight of 

financial services providers and the capital markets. We support such harmonization of the 

standards of care applicable to the provision of financial services, particularly for retail 

consumers. Given the importance of this overarching goal and in light of current efforts to 

address this issue, such as the SEC’s recently published study pursuant to Section 913 of the 

Dodd-Frank Act (“SEC Study”),5 we respectfully request that the Department withdraw the 

Proposal for further evaluation and, most constructively, collaboration with the other key 

regulators of financial services and the capital markets. 

Withdrawal or Modification

In this connection, we suggest that the Department treat the Proposal as a concept proposal 

and take the opportunity to evaluate the comments and testimony it receives as well as the SEC 

Study and to work with other regulators toward greater harmonization of applicable standards of 

care. This additional evaluation would also provide an opportunity for the Department to conduct 

further analysis as to the potential impact of the Proposal on plans subject to ERISA and 

separately as to IRAs, on financial services providers, and on the capital markets generally. This 

would also allow the Department to undertake a careful review of changes that may be necessary 

to its current administrative exemptions and interpretative positions if, as would be the case under 

the Proposal, countless current non-fiduciary service providers are converted to fiduciary status.

 

4

 Amendments to Form ADV, Investment Advisers Act Rel. No. 3060 (July, 28, 2010), 75 Fed. Reg. 49234 (Aug. 12, 

2010). 

5

 Staff of the Securities and Exchange Commission, Study on Investment Advisers and Broker-Dealers As Required 

by Section 913 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Jan. 2011), available at

http://www.sec.gov/news/studies/2011/913studyfinal.pdf.
Member FINRA/SIPC - 5 -

If, however, the Department does not withdraw the Proposal, we respectfully request that 

the Department modify the Proposal to address the concerns raised by us and other commenters 

so that the definition of fiduciary is reasonable and clear in scope, with the expanded exceptions 

which we and other commenters have identified as needed. We also request that the Department 

defer application of the Proposal to IRAs and non-ERISA plans. As noted above, the Department 

has not addressed the impact of the Proposal on this group of customers. As with ERISA plans, 

disclosure concerns for IRAs and non-ERISA plans can be readily addressed by other means. In 

addition, the Department’s concerns regarding the necessity of the Proposal to facilitate its 

enforcement activity does not apply to IRAs and non-ERISA plans, as the Department has no 

enforcement authority over such entities.6 

II. Discussion of Comments

In the following discussion, we focus our comments on the impact the Proposal would 

have on the provision of non-discretionary brokerage and related services that, under the current 

regulations, do not result in fiduciary status under ERISA or the prohibited transaction provisions 

of the Internal Revenue Code (“Code”).7 

The Proposal Substitutes an Overbroad and Unclear Test of Fiduciary Status for an 

Effective Current Test

At the outset, we respectfully disagree with the suggestion that the current regulations are 

inadequate to confer fiduciary status where appropriate. The current five-part test is a realistic 

one for determining whether providing advice incidental to the provision of brokerage and related 

services should result in fiduciary status. Although a fact-based test, it is generally understood 

and clear, and there is significant interpretative guidance as to its application. A clear 

understanding of when fiduciary status applies is important in general but is also particularly 

important in conjunction with other Department rulemakings. For example, the Department’s 

recent rule on reasonable contracts or arrangements under Section 408(b)(2)8requires a service 

provider to determine and state whether it will provide services as a fiduciary.9 We respectfully 

suggest that the Department further consider not only the general impact of the Proposal but also 

the additional impact caused by its interaction with other Department mandates.

 

6

 Differences between requirements applicable to IRAs and those applicable to plans subject to ERISA are 

recognized in other contexts. See, for example, Congress’ treatment of IRAs under Sections 408(b)(14) and 408(g) of 

ERISA in which Congress directs the Department to determine the circumstances under which fiduciary investment 

advice may be provided with respect to IRA assets. See also Prohibited Transaction Exemption (“PTE”) 86-128, 

which imposes extensive conditions with respect to certain brokerage and other transactions involving ERISA plans, 

but provides unconditional relief with respect to transactions involving IRAs.

7

 We believe that the Proposal would also greatly affect appraisers and pension consultants and have a significant 

impact on the capital markets. Since the concerns in these respects have been identified and well-addressed by other 

commenters, this comment letter does not focus on them.

8

 29 C.F.R. § 2550.408b–2(c).

9

 29 C.F.R. § 2550.408b–2(c)(1)(iv)(B).
Member FINRA/SIPC - 6 -

In addition, the current test recognizes the accepted proposition that ERISA fiduciary 

status is functional.10 The current test does not automatically confer fiduciary status on a brokerdealer simply by virtue of its also being a registered investment adviser. The Proposal, however, 

creates a presumption that any registered investment adviser is a fiduciary and disregards the 

functional test for fiduciary status. This would create an unwarranted and unfair disadvantage for 

broker-dealers like us that are dual registrants. 

The current requirements that the advice be (i) regularly provided (ii) pursuant to a mutual 

agreement, arrangement or understanding (iii) that the advice will be a primary basis for the 

plan’s (or participant’s) investment decision-making, which would be eliminated under the 

Proposal, serve to draw important distinctions between fiduciary advice and a broker-dealer’s 

occasional communications to a customer that are intended to stimulate discussion about a 

potential securities transaction for the customer and which neither party might reasonably expect 

to be a primary basis for the ultimate decision, if any, made by the customer. 

By eliminating these elements, the Proposal creates a new fact-based test of unwarranted 

breadth, uncertainty and subjectivity. The new general test under the Proposal would in essence 

convert any communication to a retirement customer or prospective retirement customer about a 

possible investment into fiduciary advice, even if it is a one-time event without further 

communication directed to the customer or prospective customer. 

This would create the very real (and possibly inadvertent) risk for a broker-dealer that 

providing general information about several possible investments for a customer’s consideration, 

without any recommendation whatsoever, would expose the broker-dealer to liability for any of 

the different independent decisions that the customer could make subsequent to receipt of the 

information. For example, the broker-dealer might provide information about security A to a 

retirement customer, and the customer might decide: to purchase or sell security A, to purchase or 

sell a different security, to maintain a current holding in security A or to maintain a current 

holding in another security, or a combination of the foregoing. Nevertheless, under the Proposal, 

the broker-dealer would be a fiduciary as to any of these actions irrespective of a mutual 

understanding as to the nature or purpose of the communication. As another example, a brokerdealer may conduct a one-time seminar for current or prospective retirement customers in which 

the broker-dealer provides the customers with a sample financial plan designed to stimulate 

further thought on the part of the customer regarding his or her options. In this situation, there is 

no expectation on the part of either party that the customer will make any particular investment 

choice based upon the sample financial plan; however, under the Proposal, the broker-dealer 

would be a fiduciary as to any action the retirement customer takes if the customer merely 

considers the sample financial plan.

The Proposal would make a financial services firm such as ours that makes generic 

research publicly available through a mass communications medium like a website or available 

through its financial advisors for business development purposes a fiduciary as to these 

communications even though the firm has no relationship with the recipients of this information 

and, indeed, may not even know their identity. This result is contrary to well-established 

principles that, in determining the application of ERISA’s fiduciary standards to a particular 

 

10

 See Pegram v. Herdrich, 530 U.S. 211 (2000); In re Mut. Funds Inv. Litig., 403 F. Supp. 2d 434 (D. Md. 2005).
Member FINRA/SIPC - 7 -

person, one begins with a determination of the person’s relationship to the plan. Yet the Proposal 

would apply fiduciary standards without the basic element of a relationship. The fact that the 

general test under the Proposal would retain the requirement that the advice be “individualized” is 

insufficient to avoid this result, unless the Proposal also includes clear guidelines as to what this 

element means. Thus, the impact of the Proposal with respect to communications to potential 

customers is particularly troublesome and, possibly, beyond the scope of ERISA, as discussed 

further below. 

The “Sales Exception” and Other Exceptions are Too Limited and Uncertain

The Proposal creates a presumption of fiduciary status for any dually registered brokerdealer as well as any other broker-dealer that provides investment-related communications to its 

customers. As a fiduciary under the Proposal, the broker-dealer would be unable to provide many 

of its standard brokerage and related services unless an exception or exemption applies.

Paragraph (c)(2)(i) of the Proposal creates what appears to be a limitation designed to 

enable broker-dealers to provide their customary services without being deemed to be fiduciaries 

(the “sales exception”). Under the sales exception, a person who has not otherwise expressly 

acknowledged fiduciary status may communicate with a plan about investments in its capacity as 

principal or as agent for a principal if that person can establish that the plan representative to 

which such communications are made knew, or reasonably should have known, that the person is 

acting on behalf of a person with interests adverse to those of the plan and that such person is not 

undertaking to provide impartial advice. However, this exception is both too limited in some 

respects and uncertain in others to provide assurance that ordinary brokerage and related services 

do not result in fiduciary status.

The sales exception appears to apply only to communications with respect to particular 

transactions. If, for example, a broker-dealer communicates general market information to a 

customer or even provides a recommendation about a particular security as to which the customer 

takes no action (or instead places an order for a transaction regarding a different security), the 

sales exception appears not to apply and the broker-dealer would be a fiduciary under the 

Proposal with respect to those communications. The sales exception also appears not to apply 

with respect to communications to a customer about services (rather than investments) offered by 

the broker-dealer, its affiliates or third parties, although such communications, if relating to an 

investment manager’s services, would be fiduciary advice under the Proposal. 

We also observe that the sales exception appears to be predicated on the notion that the 

broker-dealer has, or is acting on behalf of a person who has, interests adverse to those of the 

retirement customer. To the extent that a buyer and a seller of property may be generally 

understood to have “adverse” interests by virtue of being on opposite sides of a transaction, such 

“adversity” is a readily apparent fact to a retirement customer that intends to purchase or sell a 

security in a market transaction. In this sense, the Proposal’s use of the concept of adversity adds 

little to the Department’s professed goal of ensuring that a retirement customer understands the 

broker-dealer’s obligations to it. We note, however, that there may be no such adversity in some 

securities transactions. For example, it is questionable whether a broker-dealer that offers and 

sells shares of mutual funds to a retirement customer has or represents a person that has interests 

adverse to the customer. In this situation, the broker-dealer’s disclosure of “adverse” interests 
Member FINRA/SIPC - 8 -

may not be an accurate characterization and may be, at the very least, confusing to the intended 

beneficiary of the Proposal, the retirement customer. Further, as noted by other commenters, in 

light of the obligations that broker-dealers have under the federal securities laws (including the 

Dodd-Frank Act) and current rules and regulations of the SEC and FINRA, it may be inconsistent 

with those obligations for a broker-dealer to assert that its interests are adverse to those of its 

customer or again, at the minimum, confusing to the customer.11 

If by adverse interests the Proposal is referring to the broker-dealer’s self-interest in 

effecting a transaction for which it may receive compensation, then disclosure of the 

circumstances that present conflicts of interest is more appropriate and certainly more useful than 

a simple assertion of the broker-dealer’s “adversity.” Indeed, the Department’s concerns about 

undisclosed conflicts of interest could have been addressed in a more straightforward and less 

burdensome manner through amplified disclosure such as that required under its recent 

amendments to the regulations under Section 408(b)(2) of ERISA, which remain an appropriate 

avenue for ensuring appropriate disclosure by retirement customer service providers. 

Nevertheless, in assessing what, if any, additional disclosure may be needed for retirement 

customers, the Department should take into account not only the disclosure obligations imposed 

under current SEC and FINRA rules but also those under consideration by FINRA (“FINRA 

Notice”)12 and those that may result from the SEC Study in order to avoid redundant disclosure 

regimes or possibly inconsistent disclosure requirements. Further, as discussed below, the 

Proposal seems at odds with Congressional intent to give the SEC principal responsibility for 

assessing and, as appropriate, proposing changes to the standards of care for registered brokerdealers and investment advisers. The Proposal also conflicts with the clear mandate of the DoddFrank Act with respect to certain swap transactions and the relationship of certain service 

providers to retirement customers in those transactions. 

Clarity and certainty regarding the sales exception is particularly important given that the 

consequences of a broker-dealer’s being unable to fit within the sales exception would be 

dramatic under the Proposal. Many statutory and administrative exemptions from the prohibited 

transaction provisions of ERISA and the Code13 condition relief for the service provider seeking 

to rely on such exemptions on such service provider not being a fiduciary with respect to the 

particular transaction. As a fiduciary to a retirement customer under the Proposal, the brokerdealer would be unable to rely on these exemptions and, as a result, would be unable to continue 

 

11

 See, e.g., FINRA Rule 2010 (“Standards of Commercial Honor and Principles of Trade”); NASD Interpretive 

Material (“IM”) 2310-2 (“Fair Dealing with Customers”) (“Implicit in all member and registered representative 

relationships with customers and others is the fundamental responsibility for fair dealing. Sales efforts must therefore 

be undertaken only on a basis that can be judged as being within the ethical standards of [FINRA’s] Rules, with 

particular emphasis on the requirement to deal fairly with the public.”); NASD Rule 2310 (“Recommendations to 

Customers (Suitability)”) (requiring that a broker have reasonable grounds for believing a recommendation is 

“suitable” for a client based on the client’s financial situation and needs). See also Proposed FINRA Rule 2111 

(which would expand and clarify suitability obligations).

12

 FINRA Regulatory Notice 10-54 (Oct. 2010), available at

http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p122361.pdf.

13

 See, e.g., Section 408(b)(17) of ERISA; PTE 75-1.
Member FINRA/SIPC - 9 -

to provide a number of its important services and arrangements currently available to its 

customers. For example, the broker-dealer would be unable to effect principal transactions or 

offer credit interest programs. The broker-dealer may also be prevented from receiving certain of 

the common forms of compensation it currently receives for services, such as Rule 12b-1 fees or 

other compensation from third parties. 

Although the exceptions in paragraphs (c)(2)(ii)(B) and (C) of the Proposal relating to 

“platform” services may provide some limited ability for a broker-dealer to provide certain of its 

current services in a non-fiduciary capacity, each of these exceptions requires disclosure that the 

service provider is not undertaking to provide impartial advice. This is a particularly odd 

requirement for the (c)(2)(ii)(C) exception, which involves the provision of “general financial 

information and data,” since it seems to suggest that such information and data are not objective.

Moreover, the platform services exceptions also apply only with respect to services to an 

individual account plan and, thus, would not be available to a broker-dealer like us that has a 

substantial number of IRA customers. Thus, with the platform services exceptions inapplicable, 

the unavailability of the sales exception would have unnecessarily onerous consequences for a 

broker-dealer and its IRA customers. This disparate impact is particularly harsh given the fact 

that most IRAs are not subject to ERISA. 

The current rule, of course, needs no such exceptions to delineate between fiduciary and 

non-fiduciary services.

The Proposal Would Reduce or Eliminate Options Available to Retirement Customers

Apart from the direct impact on a person that becomes a fiduciary under the Proposal’s 

expanded new general test, the Proposal is likely to cause changes that will reduce or eliminate 

the services available to retirement customers.

In order to provide appropriate compliance and oversight of its current activities that 

would become fiduciary advice under the Proposal, a broker-dealer would incur substantial costs 

in order to continue to provide these services. It is realistic to expect that these costs ultimately 

will be borne in large measure by retirement customers. It is also likely that many broker-dealers 

will instead cease to offer any type of incidental advice to their retirement customers, contrary to 

the Department’s intent of providing increased access to better investment advice. 

If the Proposal were finalized in its current form, the incidental advice currently provided 

by a broker-dealer might instead be available only through a fee-based advisory account offered 

by the dually registered broker-dealer or its advisory affiliate. Such accounts are typically more 

expensive for the customer. Furthermore, given the prevalence of account minimum 

requirements, a significant number of would-be retirement customers, particularly IRAs, would 

not have access to these services at all.14 Even if a retirement customer is eligible for an advisory 

account, it is not necessarily the type of service or relationship that the customer wants. 

 

14

 According to research by the Investment Company Institute, the median 401(k) account balance at year-end 2009 

was $59,381, and in 2010, households owning IRAs for 20 years or more had median account balances of $87,500, 

with that number declining to $30,000 for households owning IRAs for 10 to 19 years, and $18,000 for households 
Member FINRA/SIPC - 10 -

The need in the diverse universe of retirement customers for low-cost investment 

information provided by established financial firms, and for consumer choice about alternative 

arrangements for obtaining that information, is widely recognized, yet the Proposal’s results 

would seem to present the retirement customer with fewer service alternatives or more costly 

alternatives than are currently available to it. Thus, in practical effect, the Proposal would not 

result in the “better value for service fees” that it purports to seek. 

The Proposal Would Impose Fiduciary Status on Broker-Dealers Providing Required 

Statements 

Wholly apart from the impact of its other provisions, the Proposal imposes fiduciary status 

on broker-dealers simply by virtue of providing required statements that show the value of a 

retirement customer’s investment. The Proposal would also result in fiduciary status for any IRA 

or ERISA plan custodian (or plan trustee or recordkeeper) for simply providing a statement to the 

retirement customer that includes a value for a “hard-to-value” asset held by the IRA or ERISA 

plan.

Paragraph (c)(2)(iii) of the Proposal creates a narrow exception from the general rule 

imposing fiduciary status for an “appraisal” concerning the value of securities or other property of 

the plan (“reporting exception”). But under its conditions, the reporting exception applies only 

with respect to general reports or statements with valuations provided for purposes of complying 

with the reporting and disclosure requirements of ERISA or the Code. This exception should be 

expanded to include reporting and disclosure requirements under the federal securities laws and 

commodities laws and the rules and regulations issued by the regulators under those laws.

Further, the reporting exception does not apply if the “report involves assets” for which 

there is not a generally recognized market and serves as “a basis on which a plan makes 

distributions” to participants and beneficiaries. We note that the reporting exception thus creates 

uncertainty as to how the Department might determine whether there is a generally recognized 

market for an asset. The Proposal presents little rationale as to why a broker-dealer or custodian 

should necessarily have fiduciary responsibility for values shown on a statement to retirement 

customers. For example, it makes little sense to impose fiduciary responsibility on a brokerdealer or custodian for an entire report that includes a valuation for an asset acquired several 

months or years previously (and perhaps acquired through a different broker-dealer or held by a 

predecessor custodian) and for which the retirement customer, but not the broker-dealer or 

custodian, may be receiving current information.

 

owning IRAs for less than 10 years. See Investment Company Institute, 401(k) Plan Asset Allocation, Account 

Balances, and Loan Activity in 2009 (2010), available at http://www.ici.org/pdf/per16-03.pdf; Investment Company 

Institute, The Role of IRAs in U.S. Households’ Saving for Retirement, 2010 (2010), available at 

http://www.ici.org/pdf/fm-v19n8.pdf.
Member FINRA/SIPC - 11 -

Distributions and Rollover Services

We respectfully request that the Department not expand the definition of fiduciary 

investment advice under the Proposal to cover the provision of information or recommendations 

relating to a participant’s taking a plan distribution. We agree with, and would urge the continued 

application of, the Department’s position that a recommendation to a plan participant to take a 

plan distribution is not fiduciary advice, even where combined with a recommendation as to the 

investment of the distribution.

A registered investment adviser or broker-dealer that provides distribution-related 

information or recommendations is already subject to high standard of care requirements under 

the federal securities laws and the rules and regulations thereunder.15 Moreover, defining 

“investment advice” to encompass this type of advice as a basis for fiduciary status would fail to 

recognize that a person may serve a plan subject to ERISA in different roles, which may also 

differ from the service provider’s function with respect to plan participants. Such an expanded 

definition would be particularly problematic for a firm like LPL that is dually registered but may 

communicate with plan participants regarding plan distributions in its capacity as a broker-dealer. 

In this regard, we note that the sales exception under the Proposal would appear to be unavailable 

with respect to communications about plan distributions. 

Further, there seems to be little rationale for distinguishing between a service provider’s 

providing basic information about distributions to a participant while within a plan, which would 

be a type of information covered under Interpretive Bulletin 96-1, and its providing similar 

information to a participant in connection with a terminating distribution from a plan, which 

under the suggested definition of “investment advice” would make such service provider a 

fiduciary. To the extent that the Department is concerned that persons who provide distributionrelated information and advice may have undisclosed conflicts of interest, the issue could be more 

simply and effectively addressed by the Department by expanding its current disclosure 

requirements.

The Department specifically asks whether plan participants are adequately protected from 

service providers whose recommendations “subordinate participants’ interests” to the service 

providers’ interests. Apart from the possibility of using enhanced disclosure to address conflicts 

of interest concerns, we believe that this question overestimates the service provider’s role, and 

underestimates the plan participant’s independent decision-making and actions, in connection 

with a possible plan distribution and subsequent rollover transaction. The provision of 

distribution-related information and the presentation of investment options to a plan participant, 

even where accompanied by recommendations, is but an early element in a process that involves a 

 

15

 The Supreme Court has construed Investment Advisers Act of 1940 (“Advisers Act”) Section 206(1) and (2) as 

establishing a federal fiduciary standard governing the conduct of advisers. SEC v. Capital Gains Research Bureau, 

Inc., 375 U.S. 180, 194 (1963). See also Transamerica Mortgage Advisors, Inc., 444 U.S. 11, 17 (1979) (stating that 

the legislative history of the Advisers Act “leaves no doubt that Congress intended to impose enforceable fiduciary 

obligations”). In connection with the high standards of care imposed on broker-dealers, see supra note 11. See also 

NASD Rule 2210(d) (requiring fair and balanced communications with the public); NASD Rule 2720 (requiring 

disclosure of conflicts of interest in connection with public offerings of securities); NASD Rule 3040 (relating to 

disclosure of conflicts of interest in private securities transactions); NASD Rule 2440 (relating to fair compensation); 

NASD IM-2440-1 (same); FINRA Rule 5110(c) (same); and NASD Rule 2430 (same).
Member FINRA/SIPC - 12 -

number of separate, further actions by the participant once he or she has decided to take a plan 

distribution. To impose fiduciary responsibility on a service provider solely for offering 

distribution-related information and advice disregards the several independent steps which the 

participant would need to take in order to obtain a plan distribution, to establish an IRA to receive 

a rollover contribution, to determine the investments for the IRA and to choose service providers 

with respect to the IRA. 

We note that the existing regulatory structure already provides protections with respect to 

the assets of plan participants and IRAs. To the extent that a service provider provides 

investment-related information or advice to a plan participant in connection with a plan 

distribution or an investment for an IRA, as noted elsewhere in this letter, the service provider is 

subject to obligations under the federal securities laws and the rules and regulations of the SEC 

and/or FINRA.16 As a service provider to an IRA, the provider is also subject to the strictures of 

the prohibited transaction provisions of the Code. 

In addition, making the provider of distribution-related communications and 

recommendations a fiduciary could have the practical impact of limiting consumer choice by 

depriving plan participants of the opportunity to consult with persons with whom they have any 

pre-existing relationship. A participant may have gotten to know and respect a financial advisor 

and may want that individual to be the participant’s financial advisor with respect to assets 

outside a retirement context. A participant should not be prohibited from choosing a current plan 

service provider to provide services with respect to post-distribution assets (that will not be plan 

assets after distribution), and the service provider should not be deemed a fiduciary simply by 

providing information to inform that choice. 

The Proposal Would Create Confusion Regarding the Applicable Standard of Care

On a broader level, the Proposal will likely create additional confusion in the consumer 

marketplace about the standards of care owed by financial service providers.

As the Department is aware, in general, investment advisers are subject to a fiduciary duty 

under the federal securities laws and broker-dealers are subject to an obligation of suitability in 

making recommendations to customers regarding the purchase, sale or holding of securities and to 

general standards of fair-dealing.17 Nevertheless, the exceptions to fiduciary status under the 

Proposal require disclosures that would likely add to customer confusion about the 

responsibilities of service providers, particularly broker-dealers and investment advisers that 

provide non-discretionary services. For example, as noted above, in light of the obligations that 

broker-dealers have under the federal securities laws and SEC and FINRA rules, it may be 

inconsistent with those obligations for a broker-dealer to assert that its interests are “adverse” to 

those of its customer, and at the least would be confusing to the customer, but such assertion 

would seem to be required in order to fit within the sales exception.

 

16

 Id. 

17

 Id.
Member FINRA/SIPC - 13 -

As a dual registrant that provides services in each of its capacities as an investment adviser 

and a broker-dealer, we are familiar with the challenges customers face in the current regulatory 

environment to understand the current regulatory distinctions among the various standards 

applicable to financial services providers. Although the Proposal may seek to foster greater 

understanding by a retirement customer of its service providers’ responsibilities, those services do 

not exist in a vacuum; rather, in the case of broker-dealers, they are provided in the context of a 

fundamental regulatory structure that may be poised for change. We support efforts to harmonize 

the disparate elements of the current regulatory framework. 

Although it may have been ill-timed for the Department to have issued the Proposal 

without regard for the then-pending SEC Study, there remains ample opportunity for the 

Department to collaborate with the SEC and the other key regulators. Indeed, we believe that it 

would be unwise, at best, to proceed with the Proposal without coordination with the primary 

regulators. We respectfully suggest that the Department should be mindful of the possibility that 

financial services providers may be required to significantly modify their businesses to meet new 

standards imposed by their primary regulators and not adopt rules like the Proposal that may 

conflict with those requirements. Further, the interests of retirement customers would seem better 

served by the Department’s collaboration with other regulators on possible harmonization and the 

development of more uniform standards applicable to the primary providers of financial services. 

Moreover, there are significant capital markets implications of the Proposal, which the 

Department has not considered and should consider in consultation with those regulators with 

primary responsibility and expertise with respect to these markets.

We respectfully request that the Department take a more deliberative approach to 

assessing and proposing possible regulatory enhancements with respect to service providers to 

retirement customers. This assessment should take into account the current regulatory landscape, 

including the SEC Study and the FINRA Notice, and the work of other key regulators as well as 

the relevant framework established by the newly enacted Dodd-Frank Act. This assessment 

should also consider the potential impact of any Department proposal in the context of its existing 

framework and, in particular, the continued availability of current class exemptions that are 

commonly relied upon by financial services providers.

The Proposal Would Depart from the Statutory Framework

We believe that the Proposal would result in an inappropriate (and possibly 

impermissible) departure from the established statutory framework.

Rather than determining fiduciary status on the basis of a person’s particular actions, the 

Proposal would make a person a fiduciary solely on the basis of its status as a registered 

investment adviser. (This threshold determination of fiduciary status under the Proposal is not 

mitigated by the limitation in paragraph (c)(5) of the Proposal.18) The Proposal thus would

 

18

 Paragraph (c)(5) of the Proposal provides that a person who is a fiduciary with respect to a plan by reason of 

rendering investment advice as defined in the Proposal, “shall not be deemed to be a fiduciary regarding any assets of 

the plan with respect to which such person does not have any discretionary authority, discretionary control or 

discretionary responsibility, does not exercise any authority or control, [or] does not render investment advice ... .” 

However, under paragraph (c)(1)(ii)(C) of the Proposal registered investment advisers are presumed, by their status, 

to be providing fiduciary investment advice, rendering this limitation uselessly circular. 
Member FINRA/SIPC - 14 -

expand the scope of the statutory definition beyond what Congress anticipated or intended. 

Congress clearly was and continues to be aware of registered investment advisers but has not seen 

fit to include them as fiduciaries solely on the basis of that status. 

In addition, the Proposal would confer fiduciary status on an ex post facto basis to a 

financial services provider with respect to a retirement customer with which the services provider 

had no relationship at the time of the purported fiduciary act. As discussed above, the Proposal’s 

equation of registered adviser status with fiduciary status renders this aspect of the Proposal 

particularly problematic for dual registrants like us. 

Further, as discussed above, the Proposal seems to disregard case law that recognizes that 

a person can operate in different capacities with respect to a retirement plan and its participants.19 

This oversight is particularly pertinent to the issue of providing information and recommendations 

on distributions and rollovers, as discussed above. Even if a person is a fiduciary with respect to 

certain services to a plan fiduciary, that does not mean that the person has provided or is 

providing fiduciary advice to a participant within the plan. We respectfully urge the Department 

to recognize a service provider’s different roles and services. 

III. Conclusion

In light of the foregoing, LPL respectfully urges the Department to consider withdrawal of 

the current Proposal for possible later reissuance after collaboration with the other key regulators 

in order to achieve a more consolidated and harmonized approach to addressing the standards of 

care applicable to the provision of financial services that meets the needs of the consumers of 

those services and that is the product of careful consideration of the impact on the financial 

markets. Please note that our comment letter has been signed by over 1200 individual financial 

advisors licensed with LPL who have read and agree with the comments we have provided.

 

19

 Supra note 10.
Member FINRA/SIPC - 15 -

If there is any additional information or assistance that LPL can provide to the Department in 

connection with the Department’s consideration of the comments and issues raised in this letter, 

please let us know.

Sincerely,

Michelle M. Kelley

cc: Phyllis C. Borzi, Assistant Secretary

Employee Benefits Security Administration

Stephanie L. Brown

LPL Financial LLC

Managing Director and General Counsel

Mark S. Casady

LPL Financial LLC

Chairman and Chief Executive Officer
JOHN AARONSON

Mill Creek, WA

EVA ABATE

Lake Charles, LA

DOUGLAS ABBATE

Huntington, NY

DAVID ABBS

Saginaw, MI

NED ABENROTH

Bothell, WA

DOROTHY ABREU

Kapolei, HI

THOMAS ACKERMAN

Lexington, KY

TODD ADAMS

Fort Myers, FL

CLINT ADAMS

Allen, TX

AUSTIN ADAMS

Lewisville, TX

CHRISTOPHER ADAMS

Baton Rouge, LA

DUSTIN ADAMS

Midway, KY

MARK ADAMS

Egg Harbor Township, NJ

ROBERT ADAMS

Union Springs, AL

ALAN ADDUCCI

Naperville, IL

NICHOLAS ADORNETTO

Norristown, PA

RICHARD AKINS

West Linn, OR

ROBERT ALBERTS

Denton, TX

JOHN ALESSANDRO

Barrington, RI

RUSSELL ALEXIA

Redding, CA

GLADYS ALLAM

Portland, OR

RONALD ALTHOF

Newburgh, IN

TERRY ALTMAN

Bloomfield Hills, MI

John Amos

White Hall, MD

FRANK ANDERES

Fresno, CA

GARY ANDERSON

Lexington, KY

JOEL ANDREWS

Littleton, CO

ANGELO ANELLO

Walpole, MA

THOMAS ANSTETT

Milwaukee, WI

DANIEL ANTIOHO

Elmhurst, IL

Member FINRA/SIPC
DAVID ANTYPAS

Brentwood, TN

KENNETH ARAKELIAN

Kingston, RI

TOD ARBUTINA

Cranberry Twp, PA

DIANNE ARMER

Redwood City, CA

DOUGLAS ARMEY

Fresno, CA

MITCHELL ARNOLD

Longwood, FL

WILLIAM ARNOLD

Saint Petersburg, FL

DMITRY ARSHANSKY

Farmington Hills, MI

ROBERT ASPERGER

Houston, TX

JENNIFER AUCOIN

Georgetown, CO

GABRIEL AUFIERO

Waltham, MA

ADAM AULESTIA

Baltimore, MD

PARKS AVERY

Newnan, GA

MICHAEL AXTON

Laurel, MS

THOMAS BABCOCK

Clifton Park, NY

CELIA BAEHR

Mobile, AL

CANDACE BAHR

Carlsbad, CA

ALFORD BAILEY

Everett, WA

ROB BAITINGER

Cape Coral, FL

MICHAEL BALAGNA

Brighton, MI

MARC BALDINGER

Palm City, FL

LAURA BALOUN

Canton, OH

TIMOTHY BANGERTER

Centerville, UT

VINCENZO BARBA

Point Pleasant Boro, NJ

RHONDA BARCLAY

Houston, TX

HOLLY BARE

Clovis, CA

KOREEN BARFIELD

Kailua, HI

DANIEL BARHAM

Lexington, KY

RICHARD BARNES

Brandon, MS

Katherine Barnwell

Troutman, NC

Member FINRA/SIPC
MARK BARRETT

Chico, CA

STEVE BARRILLEAUX

Sacramento, CA

RONALD BARTLETT

Lexington, SC

KATHY BARTON

Mentone, AL

KATHLEEN BAUMGARTNER

Green Bay, WI

LUIS BAUTISTA

Woodland, CA

JOHN BAYS

Marlton, NJ

JOHN BEARRIE

Arlington, TX

JAMES BEAULIEU

Somers, CT

MARTIN BECK

Naperville, IL

PETER BENEKE

North Bellmore, NY

SCOTT BENJAMIN

Augusta, GA

BRADLEY BERGDAHL

Cando, ND

CYNTHIA BERGEL

Houston, TX

RONALD BERGENSKE

Fortuna, CA

MARCELO BERNARDO

Placentia, CA

DOUGLAS BERNATH

Stryker, OH

RICHARD BERRY

Granby, CT

LEE BETHEL

Washington, DC

AMY BETTS

West Palm Beach, FL

KIMBERLY BILLER

Escondido, CA

LORETTA BIRKETT

Albany, NY

WILLIAM BISHOFF

Blacklick, OH

WILLIAM BISSELL

Evans, GA

WILLIAM BLACK

Eatonton, GA

BRAD BLACKBURN

Blythewood, SC

RICHARD BLACKSTONE

Baton Rouge, LA

DAVID BLOCKHUS

Austin, TX

GARY BLOM

Modesto, CA

SCOTT BLOOM

Del Mar, CA

Member FINRA/SIPC
JAMES BOAZ

Oklahoma City, OK

DAVID BOGLE

Sand Springs, OK

DEBORAH BOISSELLE

Toledo, OH

JIAN BOLDI

Scottsdale, AZ

JOSEPH BOLLINGER

Alexandria, LA

GINA BOLVIN

Boston, MA

GREGORY BOND

Encinitas, CA

MICHAEL BONFANTI

Prairieville, LA

DAVID BONIFACE

Wyoming, MN

MARK BOONE

Clarksville, TN

CHARLES BOOTH

Monroe, LA

ROBERT BOREK

Honolulu, HI

LINDA BORST

Ramsey, NJ

MARY BOUL

Dickinson, TX

DAVID BOULDIN

Haslett, MI

DAVID BOWEN

Tucson, AZ

ANTHONY BOYD

Kaukauna, WI

CHARLES BOYD

Ocean Springs, MS

JORDAN BOYLE

Santaquin, UT

MICHAEL BRADLEY

Smithtown, NY

RANDAL BRESSETTE

Laguna Hills, CA

Diane Brett

Hebron, CT

STEPHEN BRICKLEY

Redwood City, CA

LEON BRILLANT

Lafayette, CA

ROBERT BROCHU

Farmington, CT

PATRICK BROOKS

Savannah, GA

PATRICIA BROOKS

Haverhill, MA

DEAN BROSIOUS

Craig, CO

BRIAN BROUSSARD

New Orleans, LA

DAVID BROWER

Alexandria, VA

Member FINRA/SIPC
SCOTT BROWN

Tampa, FL

ADAM BROWN

San Diego, CA

CATHEY BROWN

Parker, CO

ROBERT BROWN

Bethlehem, PA

ALBERT BROWN

Allenhurst, NJ

RICHARD BRUCE

Sagamore Beach, MA

CHRISTOPHER BRUHL

Lakewood, CO

TIMOTHY BRUNNOCK

Morristown, NJ

ANITA BRUNO

Price, UT

LYNN BRYANT

Colleyville, TX

STEVEN BUDIN

Henderson, NV

MELODY BUNDSCHUH

Charleston, SC

KELLY BURKE

Columbus, OH

RALPH BURNETT

Edmond, OK

LINDSAY BURNHAM

Middletown, DE

KAREN BUSANOVICH

North Andover, MA

CARMELLO BUSCEMI

Laguna Niguel, CA

STACY BUSH

Valdosta, GA

JOSEPH BUTCHER

Kingston, PA

JACK BUTLER

Dubuque, IA

JULIENNE BUXTON

Novato, CA

PAUL BUXTON

Colville, WA

MARK BYELICH

Warminster, PA

DAVID CABALLERO

Raleigh, NC

CLIFFORD CADLE

South Elgin, IL

SCOTT CADWELL

Kissimmee, FL

ANTHONY CALABRESE

Harrison, NJ

MARC CALABRESE

Warren, NJ

JAMES CALDER

Dacula, GA

SCOTT CALDWELL

Greenbrae, CA

Member FINRA/SIPC
KATHY CALUWAERT

Glen Ellyn, IL

KAREN CAMPBELL

Austin, TX

STEWART CAMPBELL

Midvale, UT

GARY CAMPBELL

Olympia, WA

LARRY CANNADAY

Mount Pleasant, TX

ROBERT CANNELLA

Hillsboro Beach, FL

NIKI CANOTAS

Santa Clara, CA

CHRISTOPHER CARBONE

Loveland, OH

JERRY CARDEN

Troy, AL

EDWIN CARNEAL

Trabuco Canyon, CA

DANIEL CARNS

Cape Girardeau, MO

ROBERT CARR

Sterling Heights, MI

SCOTT CARSON

Edwardsville, IL

KATHRYN CARTER

Alexandria, VA

JOHN CARTMILL

El Cajon, CA

JOHN CARTOLANO

Scottsdale, AZ

COLIN CASEY

Troy, MI

JEFFREY CASHMORE

East Aurora, NY

WAYNE CASSRIEL

Santa Barbara, CA

MICHAEL CASTNER

Trabuco Canyon, CA

Dee Catrett

Andalusia, AL

DAVID CAUBLE

Charlotte, NC

MICHAEL CAULKINS

Milpitas, CA

CAMPBELL CAWOOD

Key West, FL

KEVIN CECIL

Raleigh, NC

EDWARD CHAIRVOLOTTI

Orlando, FL

DANIEL CHALLY

Geneva, IL

RODNEY CHAMBERLIN

Trabuco Canyon, CA

CURTIS CHAMBERS

Largo, FL

HANSEN CHAMPLIN

Harbor City, CA

Member FINRA/SIPC
PAZ CHANDRA

Dunedin, FL

EDWARD CHAPMAN

Newark, DE

STEVE CHARONIS

Belmont, CA

PAUL CHASE

Monterey, CA

KNEELAND CHASE

Treasure Island, FL

DANIEL CHAVAYDA

Rocky River, OH

SONYA CHAWLA

San Diego, CA

TIM CHERRY

Fort Myers Beach, FL

JUDITH CHIMENTI

North Hampton, NH

SUZANNE CHRISTIAN

Claremont, CA

KENNETH CHRISTIE

Granite Bay, CA

GEORGE CHRISTOPOULOS

Delray Beach, FL

PETER CIAVAGLIA

Rochester Hills, MI

JOHN CICOTTE

El Dorado Hills, CA

JOHN CINDIA

Massillon, OH

ORA CITRON

Concord, CA

CHARLES CLARK

Chattanooga, TN

JEFFREY CLARK

Flemington, NJ

ANDREW CLARK

Norwich, NY

ROGER CLARKSON

Norwich, NY

JOHN CLASSE

Frisco, TX

LEON CLAYTON

Fairfield, CA

ROBERT CLEAVELAND

Tacoma, WA

THOMAS CLINTON

Upton, MA

GREGORY CLOUGH

Arlington, VA

RICHARD COBE

Ramsey, NJ

JASON CODREA

Columbus, OH

TRACY COFFMAN

Austin, TX

DONALD COGGINS

Salisbury, NC

MARC COHEN

Henderson, NV

Member FINRA/SIPC
RICHARD COLE

McKinney, TX

JOHN COLEGROVE

Duluth, GA

KEVIN COLLIER

Gallatin, TN

PAUL COLWELL

Madison, NJ

WILLIAM CONE

Annapolis, MD

BRIAN CONEENY

Nashua, NH

DAVID CONNOR

Redlands, CA

GERALD CONWAY

Belmont, MA

JOANNE COOLEN

Hershey, PA

BRIAN COPELAND

Cedar Hill, MO

KATHRYN CORMIER

Aberdeen, SD

DAWNMARIE CORNEAU

Beverly, MA

JENNIFER CORONA

Sacramento, CA

CHARLES CORONADO

Frisco, TX

JOSEPH COSENZA

Staten Island, NY

DIANE COSTELLO

Binghamton, NY

Robert Cote

, MA

Greg Covalt

Woodward, OK

MICHAEL COWLING

Muskego, WI

GEORGE COZART

Little Rock, AR

CHRISTOPHER CRACCHIOLO

Wendell, NC

KEVIN CRAHAN

Louisville, KY

GREGORY CRAINE

Edwardsville, IL

AUDREY CREAK

Florence, OR

DANIEL CROCKER

Lancaster, PA

JASON CROIX

El Campo, TX

ROBERT CROUCH

Crossville, TN

JOSE CRUZ

Mission, TX

WESLEY CUMBIE

Flower Mound, TX

SUSAN CUMMINGS

Washington, DC

Member FINRA/SIPC
WILLIAM CUMMINS

Avon, IN

RANDY CUNLIFFE

Excelsior, MN

JASON CUNNINGHAM

Raleigh, NC

BRUCE CUNNINGHAM

Punta Gorda, FL

Paul Curran

El Campo, TX

BRANDON CURTIS

Sugar Land, TX

PETER CUSHING

Woburn, MA

DAVID CUTTER

Palm Desert, CA

DENIS CYR

Peoria, IL

GEORGE DAGHER

Brightwaters, NY

FRITZ DAHLGREN

Haddam, CT

JENNIFER DAKNIS

Yorktown, VA

SHEILA DALEY

San Jose, CA

ALAN DALTON

Wilmington, NC

CYNTHIA DALTON

Camarillo, CA

DAVID DAMASKA

Cincinnati, OH

JONNA DAMIANO

Spokane, WA

ANTHONY D'ASTICE

Glendale, AZ

JOSEPH DAVEY

Tucson, AZ

JEFFREY DAVIS

Londonderry, NH

CURTIS DAVIS

San Jose, CA

ROBIN DAVIS

Clarksville, TN

MARK DAVIS

Midlothian, VA

CHRISTOPHER DAVIS

Lebanon, OH

DANIEL DAWSON

Cocoa, FL

STEVEN DAWSON

Saugerties, NY

JOSHUA DEARMITT

Franklin, IN

PAUL DECELLES

Newport, VT

FRANKLIN DEEMS

Carrollton, GA

STRAWFORD DEES

Biloxi, MS

Member FINRA/SIPC
MARK DELANEY

Austin, TX

THEODORE DELISI

Statesville, NC

ANTHONY DELPOZZO

Phoenix, AZ

ROBERT DEMING

Fredericksburg, TX

MARTIN DEMPSEY

Berwyn, PA

MICHAEL DENNISON

San Jose, CA

ROBERT DENNY

Lafayette, LA

HEATHER DERENZO

Sacramento, CA

ELLWOOD DERRICKS

Baltimore, MD

MELBA DETLEFSEN

Springfield, OR

MIKE DEVLIN

Hingham, MA

JOSEPH DEWALD

Fort Wayne, IN

ALAN DICKSON

San Clemente, CA

ANGELA DIEHL

Clinton, NC

KEITH DIGREGORIO

Downingtown, PA

BRADLEY DILLON

Lawrenceville, IL

ANTONIO DISORBO

Burlington, CT

DAVID DIXON

North Las Vegas, NV

DENNIS DIXON

Carrollton, TX

Trey Dixon

Edmond, OK

MARK DOBRILOVIC

Mission Viejo, CA

JAMES DOLAN

Helmetta, NJ

MICHAEL DOLOHANTY

Newbury, OH

RICHARD DONAHUE

Bellingham, WA

EDWARD DOUGHTY

Charlotte, NC

THOMAS DOUGLAS

Louisville, KY

JOSEPH DOWDEY

Littleton, CO

EDWARD DOYLE

New Providence, NJ

RUSSELL DRABOLD

Tabernacle, NJ

RICHARD DRAGOTTA

Oradell, NJ

Member FINRA/SIPC
RICHARD DRAKE

Dayton, NV

James Drum

Jamestown, NC

CHRISTIAN DRUMM

Albany, NY

RICHARD DUARTE

Petaluma, CA

Bill DuBose

Mc Lean, VA

TONY DUBOSE

Davie, FL

ERIC DUNAVANT

Mandeville, LA

Mark Dunn

Rochester, MI

JAMES DUNN

Gouldsboro, PA

DOLF DUNN

Huntersville, NC

LAURA DUVALL

Veneta, OR

ROBERT EARLS

Roanoke, VA

Donna Eckert

Chicago, IL

RONALD ECKSTAM

Eden Prairie, MN

TOREY EDWARDS

Long Beach, CA

JANET EDWARDS

Van Wert, OH

RICHARD EGGERS

Stony Point, NY

STEVEN EHRMAN

Littleton, CO

KATHERINE ELLIS

Lagrange, GA

KENNETH ELLSPERMANN

Evansville, IN

ROBERT ELMS

Tulsa, OK

KEVIN ENGBERS

Sioux Falls, SD

KATHLEEN ERICKSON

Fort Bragg, CA

JOSEPH ESPOSITO

Rockville Centre, NY

DARREN EWING

Falls Church, VA

GUY FANELLI

Cheltenham, PA

FRANK FANTOZZI

Brecksville, OH

SAMI FARAG

Los Angeles, CA

MICHAEL FARRIS

Platte City, MO

JASON FARRIS

Columbus, OH

Member FINRA/SIPC
JENNIFER FELDHAUS

Shelbyville, TN

TIMOTHY FELDHEIM

Des Plaines, IL

STEVEN FERRE

Temecula, CA

BARBARA FIFE

Fishers, IN

JAMES FINLEY

San Diego, CA

JOSEPH FIORELLO

Seaford, NY

MARY FIORENZO

Erie, PA

JAMES FISCHER

Longwood, FL

CHARLES FISHER

Quarryville, PA

PEGGY FISHER

Torrance, CA

RICHARD FISHER

Elon, NC

DICK FISHER

Burlington, NC

MATTHEW FITCH

Albertville, MN

MICHAEL FITZGIBBON

Albany, NY

STEWART FLAHERTY

Westerville, OH

Steven Flaten

Eau Claire, WI

CHARLES FLEDERBACH

Dix Hills, NY

RYAN FLEISCHER

Omaha, NE

ALICIA FLEURQUIN

Flagstaff, AZ

LAURENCE FLINN

Monroe, WA

ROBERT FLOE

Pasadena, CA

JUSTIN FLORENCE

Alpharetta, GA

DOUGLAS FLUKE

Atlanta, GA

TIMOTHY FLYNN

New Rochelle, NY

NATHANAEL FLYNN

East Lansing, MI

JOHN FOARD

Concord, NC

RICK FONTANA

Rancho Cucamonga, CA

DANIEL FORAN

Annandale, NJ

GERALD FORAN

Easton, PA

JOHN FORBES

Makanda, IL

Member FINRA/SIPC
MICHAEL FORTNER

Dalton, GA

AUDREY FOSTER

Round Lake Beach, IL

RODNEY FOWLER

Cleburne, TX

ROBERT FRAGASSO

Bethel Park, PA

MICHAEL FRANKLIN

Littleton, CO

STEPHEN FRAZER

Oxford, NJ

LEERONEY FREDERICK

Sumter, SC

TRAVIS FREEMAN

Saint Louis, MO

ALAN FREI

Cameron, WI

RALPH FREIBERT

New Orleans, LA

SHARON FREIWALD

Washougal, WA

JEFFRY FRIEDMAN

Syosset, NY

ALBERT FRISS

Woodland Hills, CA

THOMAS FROST

Clovis, CA

MERIDETH FUCHS

Conifer, CO

BLAIR FUCHS

Sheridan, IL

NEAL FURLONG

Saint Louis, MO

VICTOR GADOURY

Burlington, MA

RICHMOND GALBREATH

Ponchatoula, LA

JOSEPH GALLAGHER

Gaithersburg, MD

BRENDON GALLAGHER

Chesterfield, MO

FADILAH GAMBRELL

Amarillo, TX

STUART GARDNER, Jr.

Matthews, NC

ERICA GARGOL

Phoenix, AZ

DAVID GARNER

Macomb, IL

WAYNE GARRETT

Weatherford, TX

JAMES GARRETT

San Antonio, TX

RICH GASTFIELD

Port Townsend, WA

JOHN GEARY

Palmyra, NJ

TRIPP GEBHARD

Saint Louis, MO

Member FINRA/SIPC
JUDSON GEE

Charlotte, NC

GARY GEISS

Towson, MD

THOMAS GEORGE

Willoughby Hills, OH

JENNIFER GEORGE

Terrell, TX

DAVID GEORGE

Bedford, IN

CHRISTOPHER GERBER

Minneapolis, MN

DEBORAH GERTSEN

Marion, IA

MICHAEL GHELFI

Orland Park, IL

PAUL GIANOTTI

Kankakee, IL

RALPH GILLENTINE

Cordova, TN

DAVID GILLIAM

Muncie, IN

EUGENE GILLIGAN

Sea Girt, NJ

MICHAEL GILLILAND

Colorado Springs, CO

DARLEEN GILMORE

Austin, TX

SCOTT GINGRAS

Nashua, NH

LUCAS GIORDANO

Sacramento, CA

JAMES GLOWNIA

Grand Island, NY

LARRY GOAD

Austin, TX

ROBERT GOGGINS

Sandy, UT

ADAM GOLDSTEIN

Sanford, FL

MARCO GOMEZ‐PEREZ

Hallandale Beach, FL

BRUCE GOODMAN

Danvers, MA

CHARLES GOODWILL

Cleveland, OH

DAVID GORMAN

Byram Township, NJ

MARK GOSSELIN

Dickinson, TX

JACKIE GOULAS

Leonville, LA

ISAAC GOWIN

Woodstock, GA

JEFFREY GOYETTE

Dillsburg, PA

JANETTA GRABER

Wichita, KS

Daniel Granucci

Delano, MN

Member FINRA/SIPC
John Grayson

Ramsey, NJ

MICHAEL GRAZIANO

Denver, CO

JOSEPH GRAZIANO

Centennial, CO

JEFF GRECO

Commack, NY

SHELLIE GREER

Rogue River, OR

STEPHEN GREGORY

San Ramon, CA

ROBERT GRELLA

Bellevue, WA

ROBERT M GRELLA

Newcastle, WA

STEPHEN GRESSETT

Central Point, OR

Michael Griesmeyer

Ramsey, NJ

MICHELLE GRIFFIN

Walpole, MA

David Grosjean

Avon Lake, OH

LINDA GROSSI

Reisterstown, MD

DOREDDA GROSSMAN

Fresno, CA

JOHN GUBANICH

Hinckley, OH

JEFFREY GUELLA

Lake Orion, MI

PHIL GUERRERO

Wauconda, IL

JEFFREY GUSTAFSON

Cupertino, CA

ERIC GUSTAVSEN

Afton, TN

DEAN HAALAND

Perry, IA

CHRISTOPHER HABERL

Huntington Beach, CA

LYNN HABROWSKI

Saint Clair Shores, MI

Steven Hafner

Sandusky, OH

CHRISTINE HAGEN

Mission Viejo, CA

JEFFREY HAGEN

Stillwater, MN

JEFFREY HAHN

Winchester, VA

MICHELLE HAIR

Umatilla, FL

PAUL HAIRE

Owensboro, KY

MARTIN HALBERG

Atlanta, GA

JUSTIN HALES

Grand Rapids, MI

Member FINRA/SIPC
SARAH HALL

Berlin, CT

ROBERT HALLIGAN

San Diego, CA

KEITH HAMILTON

La Jolla, CA

RONALD HAMMONS

Jarrettsville, MD

BYRON HANCOCK

San Francisco, CA

MICHAEL HANKES

Lemont, IL

JOHN HARCAR

Dana Point, CA

FREDERICK HARKINS

Providence, RI

DARYL HARR

Sacramento, CA

DAVID HARRAH

Fallbrook, CA

ANTHONY HARRIGAN

Broomfield, CO

ROBERT HARRINGTON

Salt Lake City, UT

EDWARD HARRIS

Washington, PA

EDWARD HARRIS

Yorba Linda, CA

REX HARRIS

Kalispell, MT

DICK HARSIN

Edmonds, WA

BILL HARWOOD

Columbia, SC

DEREK HASTINGS

Chico, CA

KEVIN HATCH

Los Altos, CA

JONATHAN HAULENBEEK

Northfield, CT

CINDY HAVENHILL

La Habra, CA

HOWARD HAWLEY

Gig Harbor, WA

THOMAS HAYNES

Temecula, CA

William Haynes

Denver, CO

HEATH HAYNES

Los Angeles, CA

JAMIE HEAD

Oklahoma City, OK

BEN HEADLEE

Urbana, OH

DEREK HEAP

Cookeville, TN

WILLIAM HEATWOLE

Harrisonburg, VA

MARK HEGSTROM

Inver Grove Heights, MN

Member FINRA/SIPC
WILLIAM HEINTZELMAN

Greensboro, NC

CURTIS HEINZ

Charlotte, NC

DAVID HEMLER

Westminster, MD

Mark Henderson

Somerset, KY

WILLIAM HENDRIX

Kalispell, MT

WILLIAM HENNESSEY

Saint Paul, MN

THOMAS HENRY

Columbia, MD

MICHAEL HENRY

Natchez, MS

MARK HERDING

Phoenix, AZ

JOHN HERFORD

Bellingham, WA

SUSAN HERRMANN

Scottsdale, AZ

SHARLYNN HEWITT

Wabasso, FL

BRUCE HEYMONT

Beverly Hills, CA

BENJAMIN HIERS

Goffstown, NH

PATRICK HIGGINS

Lincoln, NE

BILL HILL

Scottsdale, AZ

DEBRA HILTON

Spring, TX

BRENDA HINDS

Southborough, MA

THOMAS HITCHCOCK

Lexington, MA

WENDY HOBBS

Tucson, AZ

PAUL HOFFMAN

Appleton, WI

MICHAEL HOFMANN

Florence, AL

GREGORY HOLBEN

Richland, WA

KIM HOLLAND

Plano, TX

KEVIN HOLLAND

Naperville, IL

DOUGLAS HOLLEN

Florissant, MO

RONALD HOLLIDAY

Murrieta, CA

GRANT HOLLIDAY

Westwood, CA

JOEL HOOPER

Roseburg, OR

JOSEPH HORENCY

Hostetter, PA

Member FINRA/SIPC
REBECCA HORN

West Linn, OR

JAMES HORNING

Modesto, CA

ANDREW HOROWITZ

Stevenson Ranch, CA

GREGORY HORSTMAN

Castle Rock, CO

ANDREW HOSKINS

North Port, FL

DAVID HOWARD

Kingsland, TX

DALE HOWARD

Brawley, CA

KATHY HOWE

Rockwall, TX

TODD HOWLAND

Marina, CA

David Hozer

Southbury, CT

DAVID HRICISAK

Pittsburgh, PA

GLENN HRUSKA

Los Angeles, CA

GUY HUDMAN

Houston, TX

PATRICK HUETHER

Sparta, IL

Alan Hughes

Waynesville, OH

ELLEN HULL

Cedar Rapids, IA

ROBERT HULL

Loveland, CO

TINA HUM

Irvine, CA

Troy Hutchinson

Cumberland, WI

Jarrett Imamura

Ramsey, NJ

JAY IRVING

Kingston, MA

RAUL ISERN

Miami, FL

SUSAN IVERSON

Colorado Springs, CO

MELISSA JACOBS

Kansas City, MO

MARK JACOBS

Hermitage, TN

WAYNE JACOBSON

Cedar Falls, IA

CLAUDIA JACQUES‐SOTO

West Hartford, CT

Yale Jaffe

Darien, IL

GARY JAMES

Collinsville, MS

DARREN JANAKIS

South Berwick, ME

Member FINRA/SIPC
LAWRENCE JEANS

Everett, WA

BRADLEY JENKS

Antioch, IL

JOHN JESPERSEN

Kansas City, MO

JOHN JIALANELLA

San Juan Capistrano, CA

EVELYN JOHNS

Dallas, TX

PHILIP JOHNSON

Saint Joseph, IL

JAY JOHNSON

Steamboat Springs, CO

JOSEPH JOHNSON

Cherry Hill, NJ

MALISSIA JOHNSON

Brentwood, TN

DAVID JOHNSON

Fairmont, MN

LAURA JOHNSON

Brookeville, MD

DAVID JOHNSTON

Camarillo, CA

CLARK JOLLEY

Valencia, CA

SCOTT JONES

Yorba Linda, CA

MARK JONGEWAARD

Los Angeles, CA

BYRON JORDAN

San Antonio, TX

RODGER JORDAN

Grants Pass, OR

SHARON JOSEPH

Fredericksburg, TX

MICHAEL JOWDY

Seal Beach, CA

JAN JUMET

Boston, MA

ERIC KABLER

Johnstown, PA

WALTER KADELL

Clawson, MI

BRETT KAHRS

Wauseon, OH

KAREN KALMAN

Chandler, AZ

ARNOLD KAMINER

Longport, NJ

SCOTT KANAI

Grand Rapids, MI

TERRY KARCH

Fresno, CA

CASIMIR KARNISH

Seneca, PA

PAUL KARSON

San Mateo, CA

GREGORY KATEFF

Livonia, MI

Member FINRA/SIPC
SCOTT KAUFMANN

Fairway, KS

WARD KEEVER

Newark, DE

Thomas KEHOE

Schoolcraft, MI

Brent Keith

Tulsa, OK

ARTHUR KELLEHER

Hamden, CT

SCOTT KELLER

Lincoln, NE

SCOTT KELLER

Lincoln, NE

JOSEPH KELLEY

Scituate, MA

WILLIAM KELLY

Painesville, OH

CHARLES KELLY

Ukiah, CA

KEVIN KELLY

Stockbridge, GA

JEFFREY KENDALL

Huntersville, NC

JOHN KERR

Dover, MA

VERNER KHEDERIAN

Plymouth, MA

JOHN KIM

Medina, OH

JEFFREY KING

Hixson, TN

DARREN KINGTON

Cypress, CA

NAJALA KIRDAHY

Farmingdale, NY

David Kirkby

Sewickley, PA

ROBERT KLEINSCHMIDT

Middleton, WI

JAMES KNAPP

Kansas City, MO

DIANE KNIGHT

Chico, CA

ROBERT KNUDSEN

Oxnard, CA

JERRY KOEBEL

Summerville, SC

CAREY KOELE

Holland, MI

DAVID KOENIG

Mount Horeb, WI

Kenneth Kondas

Youngstown, OH

THOMAS KORTHALS

Cheyenne, WY

FRANK KOUCKY

Carmel Valley, CA

LINDA KOULAKJIAN

Germantown, MD

Member FINRA/SIPC
DAVID KOVICH

Pottsville, PA

Gary Kraase

Richland Center, WI

HENRY KRAMARSKI

Tabernacle, NJ

JUSTIN KRAMER

Salt Lake City, UT

LAURETTA KRAMER

Woodbine, MD

MITCHELL KRAUS

Santa Monica, CA

AMY KRAUSE

Austin, TX

DONALD KREMER

Wexford, PA

MICHAEL KRETZ

Lexington, KY

TIMOTHY KRETZ

Avon, CT

JAKUB KREUTER

Raleigh, NC

JOSEPH KRICHTEN

York, PA

RICK KROLLMAN

Fairfield, CT

STEPHEN KRUSE

Marietta, GA

PHILLIP KRZNARICH

Glendale, AZ

DENNIS KUHARSKI

Charlotte, NC

SUSAN KUHLENBECK

Pewaukee, WI

Janice Kuhn

Winchester, VA

PATRICIA KUSEK

Wrightsville Beach, NC

RAYMOND LACOURSE

Southampton, MA

Claiborne LaGrone

Tyler, TX

KEVIN LAIRD

Fremont, CA

ANDREW LAIS

Glendale, CA

PAUL LAMB

Parker, CO

ANNE LAMBERT

Bay Shore, NY

MICHAEL LANCASTER

Cypress, TX

JOSEPH LANDER

West Hartford, CT

THOMAS LANDIS

Novi, MI

STEPHEN LANE

Lawrence, KS

SCOTT LANE

Chesterfield, VA

Member FINRA/SIPC
Bob Lange

Ramsey, NJ

JENNIFER LANGSTAFF

Paso Robles, CA

DAVID LAPOINTE

Temecula, CA

DAVID LAPRAY

Idaho Falls, ID

MARK LARIMORE

Plano, TX

CHARLES LAROCCA

Brooklyn, NY

WILLIAM LARSON

Seattle, WA

ROBERT LARUE

Elizabethtown, KY

KEITH LATERRADE

Mandeville, LA

ROBERT LAUVER

Murrysville, PA

Michael Lavatori

Amelia, OH

LEE LEBOW

Houston, TX

STEVEN LECOULTRE

Waunakee, WI

CHRISTOPHER LEE

Shreveport, LA

KENNETH LEFEBVRE

Chelmsford, MA

LAWRENCE LEITCH

Cockeysville, MD

Samuel Leslie

Hattiesburg, MS

BARRY LESLIE

Chicago, IL

MARC LESTER

Denver, CO

RONALD LEVENSON

Pacific Palisades, CA

DANIEL LEVERONI

Cotuit, MA

SCOTT LEVIN

Huntington, NY

BRETT LEWIS

Lynnwood, WA

CHARLES LEWIS

Grayson, GA

MARK LIBERSHER

New York, NY

SCOTT LICHTER

Minneapolis, MN

SHAWN LIMERICK

North Chelmsford, MA

BRIAN LINDE

El Dorado Hills, CA

JAMES LINDSAY

Encinitas, CA

LAWRENCE LINDSLEY

Green Bay, WI

Member FINRA/SIPC
WILLIAM LITTON

San Diego, CA

MAMIE LIU

Potomac, MD

CARLOS LLUCH

Malibu, CA

WADE LONG

Wilmington, NC

KAREN LONGO

Scottsdale, AZ

CIRO LONGOBARDI

Wallingford, CT

ALBERT LOPEZ

Edinburg, TX

PETER LOUNSBURY

Franklin, MA

RONALD LOWE

San Ramon, CA

JACK LUBECKER

Algonquin, IL

PATRICIA LUDGATE

Reading, PA

JAMES LUNNEY

Littleton, CO

TERESA LUTTRELL

Irving, TX

Andrew Lyford

Denver, CO

JAMES LYON

Spring, TX

OWEN LYONS

Easton, MD

ROGER MABE

Eagle Springs, NC

ANDREW MACDONALD

Loveland, CO

JEFFREY MACDONALD

Wilmington, DE

MARILYN MACHA

Houston, TX

SANDRA MACKEY

Bedford, NH

SCOTT MACLISE

San Anselmo, CA

MARK MAGNUSON

Chanhassen, MN

RICHARD MAHON

Spartanburg, SC

JOHN MAHONEY

, FL

RUSSELL MAINE

Sherman, TX

ERNY MALAKOFF

San Ramon, CA

DONNA MALAND

Reno, NV

JOHN MALKOVICH

Urbana, IL

LEON MALNIK

Clarksville, MD

Member FINRA/SIPC
TIMOTHY MALONEY

West Lafayette, IN

MARK MALOUF

Redding, CA

TERESA MANSELL

Poulsbo, WA

BRADLEY MANTHEY

Louisville, KY

ROBERT MANTOVANI

Muskegon, MI

DANIEL MARCUS

Denville, NJ

LEE MARGERISON

Newark, DE

SERGIO MARIACA

Wellington, FL

SAMUEL MARINO

Baton Rouge, LA

MICHAEL MARINO

Hackettstown, NJ

BRIAN MARK

Altadena, CA

JOSHUA MARKS

Canton, OH

MICAH MARMARO

Aurora, CO

BRUCE MARTIN

Mesa, AZ

RANDY MARTIN

Chambersburg, PA

Kelley Martin

Delano, MN

MICHAEL MARTIN

Kansas City, MO

TYE MARTIN

Prairie Village, KS

MICHAEL MARTIN

Albuquerque, NM

CHRIS MARTIN

New Orleans, LA

STACY MARTIN

Riner, VA

CHRISTOPHER MARTINO

Madison, VA

MICHAEL MASON

Macedon, NY

GARY MATHEWS

Maineville, OH

ROBERT MATSON

Millis, MA

SANDRA MATTERN

Spearfish, SD

MICHAEL MATTIE

Warminster, PA

REBECCA MAURER

Indianapolis, IN

REGINALD MAXFIELD

Sandy, UT

CHARLES MAXIM

Mason, OH

Member FINRA/SIPC
MARGUERITE MAXWELL

Arvada, CO

DAVID MAYNARD

Winston Salem, NC

RONALD MAZZARELLA

Livingston, NJ

THOMAS MCAULIFFE

San Rafael, CA

MORGAN MCCANDLESS

Saint Louis, MO

JOHN MCCARTHY

North Attleboro, MA

SUSAN MCCARTHY

Chicago, IL

DAVID MCCLELLAN

Saint Simons Island, GA

CORY MCDANIEL

Ridgefield, WA

SEAN MCDERMOTT

Saint Paul, MN

BRANDT MCDONALD

Montgomery, AL

DON MCDONALD

Rome, GA

MARIEL MCGEHEE

Tulsa, OK

KARL MCGHEE

Pittsburgh, PA

ALISON MCGONAGLE

Sun City West, AZ

FRANK MCGOVERN

Great Falls, VA

ROBERT MCGOWAN

Canfield, OH

LISA MCGRATH

Shelby Township, MI

TIMOTHY MCGRATH

Wheaton, IL

JOHN MCKAY

San Diego, CA

MARK MCKEAGUE

Kaneohe, HI

MICHAEL MCKENZIE

Plymouth, WI

LADD MCKITTRICK

Portland, OR

CONNIE MCLAUGHLIN

Seal Beach, CA

CASEY MCLAUGHLIN

Waterloo, IA

JAMES MCLAUGHLIN

Media, PA

TIMOTHY MCMANUS

Port Saint Lucie, FL

KEVAN MCNAUGHT

Berthoud, CO

LISA MCSTRAVICK

Golden, CO

DAIL MEIKLE

Glendale, AZ

Member FINRA/SIPC
GARY MENCONI

Woodridge, IL

JOHN MENDRYSA

Schenectady, NY

JEFFREY MENOUGH

South Elgin, IL

LUZ MERAZ‐JOHNSON

Orangevale, CA

GREGORY MERLINO

Marlton, NJ

CHIP MESSENGER

San Diego, CA

GARY MESWARD

Colorado Springs, CO

BRAD MIDDENDORF

Wayzata, MN

MICHAEL MIDTVEDT

Mount Pleasant, SC

MATTHEW MIESKE

Midland, MI

Pete Miller

Fort Wayne, IN

JAMES MILLER

Charlottesville, VA

JUDY MILLER

Redwood City, CA

SHARI MILLER

San Diego, CA

SAMUEL MILLSAPPS

Acworth, GA

JULIE MINAMI

Santa Maria, CA

CHRIS MINCHEFF

Sparta, IL

THOMAS MINOR

Sherman Oaks, CA

RICHARD MISKEWITZ

Mountainside, NJ

WILLIAM MITCHELL

Austin, TX

BRIDGET MITCHELL

Cincinnati, OH

LANCE MIYAHIRA

Kaneohe, HI

BASSEM MOEZ

Farmington Hills, MI

ANEL MOLINA

Pembroke Pines, FL

PABLO MOLINA

Gaithersburg, MD

CHRISTOPHER MOLLAN

Farmington Hills, MI

DAVID MOLNAR

Avon, OH

BENJAMIN MONREAL

Clovis, CA

STEVEN MONTGOMERY

Coopersburg, PA

George Montgomery

Canton, TX

Member FINRA/SIPC
REED MOORE

Tacoma, WA

AARON MOORE

Port Clinton, OH

ERIC MOORE

Merrick, NY

DEIDRE MOORE‐KEYLON

Chattanooga, TN

GERARD MORDA

Lake Mary, FL

DAVID MOREHEAD

Escondido, CA

RAFAEL MORENO

Key Biscayne, FL

BETH MORGAN

Acworth, GA

KIRBY MORRISON

Alpine, CA

RYAN MORRISSEY

New Haven, CT

DANIEL MORSE

Maple Shade, NJ

MARY MORSE

Morristown, NJ

CLYDE MOSIER

Saratoga, CA

AMY MOTELET

Fall Creek, WI

WENDY MUELLER

Bay City, MI

DAVID MUILENBERG

Grand Rapids, MI

DWAYNE MUKAI

Hilo, HI

MATT MULLENIX

Urbandale, IA

WALTER MUNOZ

Rockaway, NJ

RICHARD MURPHY

Scarborough, ME

BRIAN MURRAY

Johnson City, TN

MARK MUSCHICK

Chesterfield, MO

JAMES MUSGRAVE

Silver Spring, MD

LAWRENCE NACK

Hewitt, WI

John Nave

Bethel Park, PA

BRADLEY NEAL

Lincoln, IL

CHRISTOPHER NEI

Cave Creek, AZ

TROY NEILY

Litchfield, NH

GARY NELSON

Kennewick, WA

CHRISTOPHER NEUBERT

Easton, CT

Member FINRA/SIPC
KATHLEEN NEUMANN

Ridgewood, NJ

KELLY NEWELL

San Diego, CA

DOUGLAS NEWMAN

Stowe, VT

JEREMY NEWTON

Lewisville, TX

MIKE NIELSON

Erie, CO

STEPHEN NIEZGODA

Dearborn, MI

REBECCA NILSEN

Mesa, AZ

CLARK NISBETT

Austin, TX

GERALD NISSLY

Danbury, CT

KIMBERLY NITZ

Mechanicsville, VA

TIMOTHY NITZ

Mechanicsville, VA

PHILIP NOBLE

Ottawa Hills, OH

Jeffrey Nolan

Ramsey, NJ

MATTHEW NOLL

Greensburg, PA

BARBARA NORMAN

San Diego, CA

ROBERT NORTON

Hammonton, NJ

MARY NOTHELFER

Allentown, PA

LEE NUGENT

Slidell, LA

VAUGHN NUN

Derby, KS

DAVID O'BLOCK

Irwin, PA

RYAN OBST

Clifton Park, NY

TIMOTHY O'CONNOR

Rutland, VT

WILLIAM O'CONNOR

Trabuco Canyon, CA

JUAN OECHSLE

Annapolis, MD

JAMES OLSON

Sarasota, FL

JAMES OLSON

Altadena, CA

BRANDON OLSON

Prairie Farm, WI

DOUGLAS ORIFICE

Watertown, MA

JONATHAN OSTERKAMP

Chandler, AZ

JOHN OSTNER

Little Rock, AR

Member FINRA/SIPC
RICHARD OZOLS

Oro Valley, AZ

WILLIAM PADEK

Overland Park, KS

ROSS PAKE

San Juan Capistrano, CA

BALDASARO PALMENTERE

Kansas City, MO

FRED PALMER

Prairieville, LA

NICOLE PALMER

Prairieville, LA

JACOB PALTZER

Bend, OR

THOMAS PAPA

Dix Hills, NY

MICHAEL PAPPAS

Denver, CO

GERALD PARENT

Assonet, MA

SONG PARK

Centreville, VA

GRAHAM PARSONS

Erie, PA

SEAN PATRICK

Ventura, CA

LINDA PAXTON

Portland, OR

CAROLE PECK

Fort Myers, FL

GARY PELLETIER

Bedford, NH

VIRGINIA PERKINS

Northfield, NH

JOSEPH PERRI

Melville, NY

JANICE PERRY

Benton, PA

JEFFREY PESKIN

Houston, TX

DEBORAH PETERSON

Colorado Springs, CO

SHARON PETERSON

Poway, CA

SARAH PETERSON

Colorado Springs, CO

DAVID PETOSKEY

Bloomfield Hills, MI

SALVATORE PETRALIA

Methuen, MA

LORIAN PETRY

Newport Beach, CA

TOD PHILLIPS

Novi, MI

THOMAS PICARDY

Grand Rapids, MI

JOHN PICONE

Bonita Springs, FL

JACK PIETRA

Snohomish, WA

Member FINRA/SIPC
RICHARD PIETSCH

Chesapeake, VA

Erik Pinter

Appleton, WI

BRUCE PIVAR

Naples, FL

SUSAN POKWATKA

Saint Clairsville, OH

TIMOTHY POLLARD

Lexington, NC

GREGORY POLYAK

Chagrin Falls, OH

MIKEL POULSEN

Wenatchee, WA

WILLIAM POWELL

Rosenberg, TX

SUSAN POWELL

Villa Park, CA

JOHN POWER

Surprise, AZ

PAUL POZNANTER

Carlsbad, CA

MICHAEL PULTRO

Doylestown, PA

DAVID PURDY

Forest Lake, MN

MARK QUERY

Lexington, KY

JOHN QUIGGLE

Sanford, NC

LARRY RAABE

Glenwood, IA

LARRY RABER

Valparaiso, IN

HARRY RADCLIFFE

Lancaster, PA

NICOLAS RADISAY

Laguna Beach, CA

NANCY RADZYMINSKI

North Royalton, OH

PETER RAFANIELLO

Findlay, OH

PETER RAFANIELLO

Findlay, OH

JOAN RAGAN

Wisconsin Dells, WI

DONALD RANDOLPH

Sparta, TN

LAWRENCE RATICK

Highland, NY

DENISE RAU

Lake Charles, LA

THEODORE RAUBER

Spencerport, NY

CHRISTIAN RAVSTEN

Castle Rock, CO

CHRISTOPHER RAVSTEN

Parker, CO

GRANT RAYMOND

San Clemente, CA

Member FINRA/SIPC
ROBERT REAUME

Beverly Hills, MI

PATRICK REDDING

Logan, UT

JOSEPH REED

Cedar Park, TX

JACK REED

Phoenix, AZ

GAY REEVES

Carlsbad, CA

Ryan Reeves

Charleston, SC

TIMOTHY REEVES

Midlothian, IL

NADINE REFSELL

Danville, CA

MARTIN REGAN

Sylvania, OH

JAMES REINIG

Lakewood, CO

MARK REISMEIER

Altoona, PA

MICHAEL REITER

Swampscott, MA

CAROL REMY

Gibsonville, NC

GEORGE RENDON

Laguna Niguel, CA

MICHAEL RENNAKER

Spokane Valley, WA

VICTORIA RENNE

Chino, CA

JOHN REUTEMANN

Potomac, MD

Jimmy Rhymer

Honolulu, HI

DAVID RIBACK

Portland, OR

DONALD RICH

Kalispell, MT

CHRISTOPHER RIGGS

Petersburg, VA

WAYNE RIGNEY

Little Rock, AR

JON RILEY

Charlotte, NC

DAVID RILEY

Henderson, KY

THOMAS RINDAHL

Phoenix, AZ

CHRISTOPHER RISCHE

Oak Harbor, WA

RICHARD RIVA

Costa Mesa, CA

Wesley Robbins

Johnson City, TN

BOBBY ROBERTS

Panama City, FL

STEPHEN ROBERTS

Silverton, OR

Member FINRA/SIPC
GERALD ROBILLARD

Plymouth, MA

CYNTHIA ROBINSON

Simi Valley, CA

ANDREW ROBLING

Evansville, IN

JOSEPH W ROCCO JR

Fairfield, CT

JASON ROEN

Madison, WI

PHILIP ROGERS

Drexel Hill, PA

MICHAEL ROHLING

San Diego, CA

WILLIAM ROMEO

Coconut Creek, FL

EDWARD RONAN

Franklin, MA

CHARLES ROOT

Santa Rosa, CA

MICHAEL ROSENBERG

Livingston, NJ

LEE ROSENWASSER

Nanuet, NY

JACK ROTHENBERG

Oak Park, MI

PETER ROWE

Phoenix, AZ

RICHARD ROY

Windham, ME

JOHN ROY

Plymouth, NH

DARREN ROYAL

Castle Rock, CO

BRIAN RUTTLE

Princeton, MA

MICHAEL RYAN

Windham, NH

ROBIN SAAR

Shannon, IL

JAMES SALAMONE

Baltimore, MD

JOEL SAMBURSKY

Carbondale, IL

DAVID SAMICK

Holliston, MA

ARMIDA SANCEN

Martinez, CA

TERESA SANDERS

Littleton, CO

BUD SANFTNER

Des Moines, IA

JAIME SANTANA

Dallas, TX

LOUIS SANTORO

Long Beach, CA

KEN SAVELLS

Harrison, AR

JOHN SAWYER

Canton, MA

Member FINRA/SIPC
BRUCE SAWYER

Gray, ME

SUSAN SAXTON

Kansas, IL

JAMES SCANLAN

North Kingstown, RI

KEITH SCHAEFBAUER

Sioux Falls, SD

DAVID SCHAPER

Corona, CA

JAMES SCHERER

Roseville, CA

SCOTT SCHIAVONE

Prospect, KY

VIVIENNE SCHLEU

Boca Raton, FL

KENT SCHMIDT

Baldwinsville, NY

DAVID SCHMIDT

Germantown, TN

WILLIAM SCHNEIDER

Lady Lake, FL

Michael Schoeder

Janesville, WI

JAY SCHONFELD

Beachwood, OH

ANN SCHUELER

Knoxville, TN

EUGENE SCHULFER

Custer, WI

JAY SCHULMAN

Hudson, OH

KENNETH SCHULZ

Tomahawk, WI

FRANK SCIECINSKI

West Chester, PA

Robert M Scola

La Jolla, CA

SHAUN SCOTT

North Kingstown, RI

Joyce Search

Franklin, OH

MICHAEL SEBESTA

Granite Bay, CA

FREDERICA SEE

Brookline, MA

MICHAEL SEESE

Parkersburg, WV

SANDIP SEHMI

Irvine, CA

DAVID SEVER

Lawrenceburg, KY

BRIAN SHACKLEFORD

Ladera Ranch, CA

RICHARD SHANLEY

La Grange, IL

MARGARET SHARD

Grand Blanc, MI

JAMES SHAW

Visalia, CA

Member FINRA/SIPC
TRAVIS SHEETS

Woodridge, IL

ANTHONY W. SHEFFIELD

Spring Hill, TN

JAMES SHELTON

Austin, TX

DOUGLAS SHEPLER

Fort Wayne, IN

DANIEL SHEVLIN

Thornton, PA

ELIAS SHIHEIBER

Las Vegas, NV

PHILIP SHIVELY

Columbus, OH

JOSEPH SHORTT

Scottsboro, AL

MARIE SIEBER

Clifton, NJ

CHRISTOPHER SIEG

Minneapolis, MN

STEPHEN SIGMON

Norfolk, VA

KENT SIKES

Keller, TX

ROGER SIMMONS

New Braunfels, TX

PATRICIA SIMMS

Brunswick, GA

MICHAEL SIMONDS

Macomb, MI

VAL SIMSON

Chatham, NJ

JUDITH SINCLAIR

Baton Rouge, LA

GILBERT SINGER

Hamden, CT

BRIAN SINGLETON

Pocatello, ID

JEANETTE SIX

Greenville, SC

JOEL SKIPPER

Columbia, SC

RONALD SKIPPER

Blythewood, SC

TREVOR SKIPPER

Murfreesboro, TN

Michael Skubon

Prescott, AZ

FRANK SLACK

Bristol, VA

BRIAN SLADE

Riverton, UT

KEVIN SLATTERY

Westerlo, NY

STEPHEN SLOAN

Marion, MT

RYAN SMITH

Richmond, VA

PETER SMITH

South Lyon, MI

Member FINRA/SIPC
ANNA‐MARIE SMITH

Sanbornville, NH

GERALD SNYDER

Brecksville, OH

CRAIG SNYDER

Troy, MI

SCOTT SOLOMON

Columbus, GA

Daniel Sommers

Saint Joseph, MO

DAVID SOMMERS

Norwalk, IA

TODD SONGSTAD

Saint Michael, MN

SIDNEY SORIA

Farmington, UT

LYNN SORIANO

Yukon, OK

ANDREW SOSNOWITZ

Phoenix, AZ

PETER SPAN

Sherman Oaks, CA

PHILIP SPENCER

Carlsbad, CA

STEPHEN SPOLTMAN

Fort Wayne, IN

CHRISTOPHER SPOLTMAN

Fort Wayne, IN

STEPHEN SPURRIER

Baltimore, MD

DAXS STADJUHAR

Roseville, CA

EDWARD STADJUHAR

Rocklin, CA

DIANE STAFUTTI

East Hanover, NJ

CHRISTOPHER STALLINGS

Loganville, GA

CHERYL STALLINGS

Amarillo, TX

STEVEN STAMBAUGH

Lakeland, FL

GRETCHEN STANGIER

Happy Valley, OR

JEREMY STANLEY

Winston Salem, NC

LARRY STAPP

Midland, TX

JEFFREY STARK

Lafayette, CA

BETTY STATON

Mount Sterling, KY

THOMAS STEFANIAK

Denver, CO

CHRISTOPHER STEIN

Round Lake, IL

GREGORY STELNICK

Delano, MN

HARLAN STEPHENS

Rapid City, SD

Member FINRA/SIPC
CHRISTINE STERN

Santa Monica, CA

RANDALL STEWART

Ballwin, MO

BRADLEY STIPP

Charlotte, NC

ROBERT STOKLOSA

Buffalo, NY

JOSHUA STRITTMATTER

Azle, TX

KYLE STROUD

North Little Rock, AR

TRACY STROUS

Kenton, OH

MARILYN STRUCHEN

Cedar Rapids, IA

PAULA STRUMBLY

Willoughby, OH

WYNETTE STUNTZ

Houston, TX

PRISCILLA SUHRE

Lakewood, WA

ROBERT SULLIVAN

Aurora, IL

MICHAEL SULLIVAN

Westmont, IL

GORDON SUN

Honolulu, HI

KEVIN SUPKA

Jenkintown, PA

KATHRYN SUPKO

Boise, ID

MARK SWARTZENDRUBER

Chicago, IL

JEFF SWEAT

Jacksboro, TN

Jason Swink

Shelby, NC

WILLIAM SYLVIA

Acushnet, MA

BERNARD TAILLON

Denver, CO

JENNIFER TANCK

Saint Petersburg, FL

MICHAEL TANNERY

Richardson, TX

TIMOTHY TARANTO

Ocean Springs, MS

CHRISTINE TARR

Waterford, VA

Carol Tartaglia

Branford, CT

DEBRA TAYLOR

Franklin Lakes, NJ

TOD TAYLOR

Traverse City, MI

TINA TAYLOR

Bowling Green, KY

ROBERT TEIK

South Barrington, IL

Member FINRA/SIPC
MICHEL TENAGLIA

Leonard, MI

LES TERRILL

Dallas, TX

JAMES TERRY

Palmetto, FL

BENJAMIN TEXLER

Delaware, OH

MICHAEL THEBERGE

Cambridge, MA

DAVID THIBEAULT

Winthrop, MA

Peter Thomas

Wichita, KS

BARRY THOMAS

Johnstown, PA

JOHN THOMPSON

Germantown, TN

WILLIAM THOMSON

Denver, NC

LEE THOMSON

Prosper, TX

BRUCE THUE

Lawndale, CA

RUTH TIMME

Avon, CT

MARK TOBER

San Clemente, CA

DAVID TODD

Kaysville, UT

STILSON TOMITA

Arlington, MA

LOIS TOOHEY

Chanhassen, MN

JARRETT TOPEL

Oakland, CA

DARREN TOSETTO

Scottsdale, AZ

BRUCE TRAHERN

Prescott, AZ

CHRISTINE TRAPP

Itasca, IL

KEITH TRENT

Shallowater, TX

DANIEL TRESEMER

Geneva, IL

JUAN TREVINO

McAllen, TX

JOHN TRILLER

Fishers, IN

JAMES TRIOLO

Richmond, TX

ANTHONY TSANG

San Francisco, CA

ERIC TUCKER

Saint Petersburg, FL

BOB TUCKER

Vienna, VA

DAVID TUCKER

Noblesville, IN

Member FINRA/SIPC
MICHAEL TUCKER

Dunlap, IL

ALAN TUCKER

Barrington, IL

THOMAS TULLY

Brookfield, WI

TOM TYE

Danville, KY

KEITH TYNER

Fishers, IN

JOHN ULSHAFER

Midlothian, VA

HARRY URIAN

Newtown Square, PA

GEORGE URIST

Tully, NY

BRIAN URSU

Cedar, MI

DAVID UTTERBACK

Coon Valley, WI

JOAN VALENTI

Unionville, CT

EUGENE VALLECORSA

Beaver Falls, PA

LIONEL VALLEY

Chico, CA

STEPHEN VALOVICH

Palm Beach Gardens, FL

MIKE VANDENBERGE

Spokane Valley, WA

MIKE VANDENBERGE

Spokane Valley, WA

JAMES VANDERBEEK

Hyrum, UT

MARK VANLEEUWEN

Lexington, KY

KENNETH VANLEEUWEN

Sea Isle City, NJ

PAUL VANNORMAN

Mount Sterling, KY

ARRON VARN

Aurora, CO

SALVATORE VENTIMIGLIA

Grosse Pointe Woods, MI

THOMAS VICKERS

Garnet Valley, PA

KENNETH VIENS

Waterville, ME

Thomas VIGIL

Paso Robles, CA

TAUNYA VILLICANA

Tucson, AZ

JEFFREY VINCENT

Riverton, WY

JEFFREY VINCENT

Salt Lake City, UT

JAY VIRTUE

Saint Louis, MO

MARC VISCOMI

Pittstown, NJ

Member FINRA/SIPC
THEODORE VOGT

Belmont, MI

DAVID VOLLMER

Chatham, NJ

JEFF VONCOLLN

Ogden, UT

DAVID VOYDIK

Beaverton, OR

ROBERT WADE

Ottawa Hills, OH

CHRISTOPHER WAGNER

Lonsdale, MN

WAYNE WAGNER

Pennsville, NJ

GREGORY WALKER

Frederick, MD

WESLEY WALKER

Greenville, SC

RANDY WALLACE

Jackson, TN

DANIEL WALLACH

Boston, MA

GENA WALLIS

Palo Alto, CA

Kevin Walrath

Chicago, IL

MARK WALSVICK

Santa Rosa, CA

JEFFREY WARD

Long Beach, CA

ROBERT WARD

Carthage, NC

KELLY WARING

Arcadia, CA

ROBERT WARING

Arcadia, CA

PETER WASHBURN

Little Compton, RI

Eric Wasson

Naperville, IL

DONALD WATERBURY

Vero Beach, FL

SHELBY WATSON

West Monroe, LA

FRANK WATTELET

Joplin, MO

KELLY WEAVER

Davidson, NC

SCOTT WEBB

Zanesville, OH

GLENN WEBER

Canton, GA

BART WEILER

Pataskala, OH

STEVEN WEINSTEIN, CFP

Middletown, OH

KERRY WEISS

Marysville, OH

TODD WELCH

Royersford, PA

Member FINRA/SIPC
JANE WELCH

Liberty Twp, OH

JAMES WELDEN

Newnan, GA

TERRY WELLS

Sudbury, MA

KEVIN WELLS

Carmel, IN

DAVID WELSH

Overland Park, KS

ALVIN WELTON

Durham, NC

WHITNEY WESTGATE

Overland Park, KS

TRAVIS WETZEL

Frederick, MD

JEFF WHITE

Honolulu, HI

JAMES WHITENER

San Diego, CA

JONATHAN WHITLOCK

Apple Valley, CA

TERRY WHITNEY

Kingwood, TX

ron whittingham

Tyler, TX

MELVYN WICKS

Maumee, OH

MARY WIEDENMEIER

Oshkosh, WI

ERICK WIEGAND

Orangevale, CA

THOMAS WIELGUS

Mill Creek, WA

LARRY WIENS

Danville, CA

TINA WILCOX

Durham, NC

FREDERICK WILKE

Stone Ridge, NY

JOHN WILKERSON

Aurora, OH

WILLIAM WILKINS

Mason, OH

ROBERT WILLIAMS

Hilo, HI

MICHAEL WILLIAMS

Chester Springs, PA

RICHARD WILLIAMS

Tualatin, OR

MICHAEL WILLIAMS

Longmeadow, MA

DEAN WILLIAMS

Santa Rosa, CA

THOMAS WILLIAMS

Wilmington, DE

ANTHONY WILLIAMS

Houston, TX

DAVID WILLIAMSON

Palo Cedro, CA

Member FINRA/SIPC
James Wilson

Saint Charles, MO

DEBORAH WILSON

Brighton, CO

TONY WINKELJOHN

Fort Wayne, IN

KAREN WINSLOW

Falmouth, ME

ROBERT WINSTON

Stow, OH

GARY WINTERHOF

Cedar Falls, IA

RUSSELL WINTHROP

Portsmouth, RI

MARK WINTHROP

Hopkinton, MA

EARL WINTHROP

Avon, CT

MICHAEL WISEMAN

Hermitage, PA

KEITH WOERTZ

Dunlap, IL

JUSTIN WOLFE

Wilmington, NC

DEBORA WOOD

Tucson, AZ

BRUCE WOODBURY

Folsom, CA

DIANE WOODWARD

San Ramon, CA

MICHAEL WORAM

Dallas, TX

RONALD WORKMAN

Pismo Beach, CA

KENNETH WORLEY

Wichita Falls, TX

BRANDON WORLEY

Gonzales, LA

ALFRED WORNALL

Greenwood, SC

THOMAS WORTH

Brighton, CO

GEORGE WOYCHIK

River Falls, WI

GREGORY WOZNIAK

Lees Summit, MO

RONALD WROBEL

Lemont, IL

CAROL YAZEL

Texarkana, TX

KENNETH YOUNG

Jacksonville, FL

JAMIE YOUNG

San Antonio, TX

RANDALL YOUNG

Lexington, KY

BRUCE YOUNG

Omaha, NE

CHERI YU

San Francisco, CA

Member FINRA/SIPC
GRACE YUNG

Houston, TX

MICHAEL YURKOVIC

Dickson City, PA

MAXIM YUTSIS

New York, NY

PAUL ZAHORCHAK

Roanoke, VA

GREGORY ZALE

Gilbert, AZ

STEVEN ZARR

Minot, ND

MARIANNE ZAWACKI

Ayer, MA

JAMES ZBACH

Erie, PA

JARED ZEISER

Hot Springs National Park, AR

KIRBY ZELLER

Colorado Springs, CO

GARY ZENT

Noblesville, IN

KEVIN ZIMMER

Clayton, CA

ANDREW ZITTELL

San Francisco, CA

FRANK ZOCCO

Middletown, CT

Milo Zonka

Palm Bay, FL

MICK ZWAYER

Columbus, OH

Member FINRA/SIPC